Part III Annex F

Spill Prevention, Control and

Containment Plan
Version 2.0

January 2015

Yara Dallol Potash Project, Danakil Depression,

Ethiopia

Document Ref. Prepared By Reviewed By Date Submitted to

Yara Dallol BV for
Review
0224244_V1.0_SPCCP Dieter Rodewald Mike Everett November 2014
0224244_V2.0_SPCCP January 2015

This report has been prepared by Environmental Resources

Management the trading name of Environmental Resources
Management Southern Africa (Pty) Limited, with all reasonable skill,
care and diligence within the terms of the Contract with the client,
incorporating our General Terms and Conditions of Business and
taking account of the resources devoted to it by agreement with the
client.

We disclaim any responsibility to the client and others in respect of

any matters outside the scope of the above.
 CONTENTS

LIST OF ACRONYMS 2

DEFINIITIONS 1-1

1 INTRODUCTION 1-1

1.2 PURPOSE AND SCOPE 1-3

1.3 LINKAGE TO OTHER ENVIRONMENTAL AND SOCIAL PLANS 1-3

2 SUMMARY OF LEGAL AND OTHER REQUIREMENTS 2-1

2.1 NATIONAL LEGISLATION AND POLICY 2-1

2.2 INTERNATIONAL FINANCE CORPORATION (IFC) PERFORMANCE STANDARDS 2-1

3 OVERALL ACCOUNTABILITY AND RESPONSIBILITY FOR THIS

PLAN 3-1

4 SPILL MANAGEMENT DURING THE CONSTRUCTION, OPERATION

AND DECOMMISIONING/CLOSURE PHASES 4-1

4.1 SPILL HAZARD IDENTIFICATION 4-1

4.2 PRELIMINARY LIST OF HAZARDOUS CHEMICALS 4-2
4.3 SPILL PREVENTION MEASURES 4-2
4.4 SPILL CONTROL AND COUNTERMEASURES 4-3
4.5 SPILL RESPONSE SUB-PLANS 4-4
4.6 TRANSPORTATION OF HAZARDOUS MATERIALS AND CHEMICALS 4-5
4.7 SPILL EMERGENCY PROCEDURES 4-6
4.8 TRAINING 4-7

5 COSTS FOR SPILL PREVENTION, CONTROL AND CONTAIMENT 5-1

5.1 CONSTRUCTION AND OPERATIONAL PHASE 5-1

5.2 DECOMMISSIONING AND CLOSURE PHASE 5-1

6 VERIFICATION, MONITORING AND REPORTING 6-1

6.1 VERIFICATION, MONITORING AND REPORTING PLAN 6-1

6.2 KEY PERFORMANCE INDICATORS 6-2
6.3 COSTS FOR VERIFICATION AND MONITORING 6-2

7 SPILL PREVENTION, CONTROL AND CONTAINMENT PLAN

SUMMARY 7-1
LIST OF ACRONYMS

Abbreviation Full Definition

ANRS Afar National Regional State
APELL Awareness and Preparedness for Emergencies at Local Level
CHSSMP Community Health, Safety and Security Management Plan
ERP Emergency Response Plan
ES-MS Environmental and Social Management System
ESIA Environmental and Social Impact Assessment
IFC International Finance Corporation
IMCP Integrated Mine Closure Plan
KPIs Key Performance Indicators
MSDS Material Safety Data Sheets
PS Performance Standard
SOPs Standard Operation Procedures
SPCCP Spill Prevention, Control and Containment Plan
UNEP The United Nations Environment Programme
WAMP Water Management Plan
WMP Waste Management Plan
DEFINIITIONS

The following definitions are of relevance within this report:

 Accident – an unintended incident which results in injury to persons

and/or damage to property, the environment, third party or which leads
to production loss.

 Emergency – a situation where there is an immediate threat to

communities, personnel or the environment.

 Employees – full time and part time employees of Yara Dallol BV (i.e. –
salaries paid directly to individuals by Yara Dallol BV).

 Incident – a sudden unintended work related accident which results in –

or has the potential for (near miss) – injury, and/or business interruption,
and/or damage to property, the environment or a contractor.

 Near Miss – an unintended incident not leading to injury or damages, but

which under different circumstances could have become an accident.

 Site – refers to the area in which the Yara Dallol Potash Project operates,
including processing plant, evaporation ponds, tailings management area,
solution mining area, staff living quarters, haul road through to the Port of
Tadjoura, Djibouti, the Port of Tadjoura.

 Yara Synergi Database – a Yara Dallol BV database for registration of all

incidents with injury of people, environmental incidents, incidents with
property damage or loss of production and security breaches. Incidents are
reported according to definitions and classification given in Yara TOPS 0-
01 “Reporting of Accidents, Near-miss Incidents, Sickleave, Environmental
Incidents and Security Breaches”

 Contractors – persons working for external companies (or employed by an

employment agency) that are under contract to carryout for the unit, but
not being part of the unit’s workforce.

 TOPS 0-01 – an existing Yara Dallol BV procedure titled “TOPS 0-01

Reporting of Accidents, Near-miss Incidents, Sick Leave, Environmental
Incidents and Security Breaches”

 TOP 0-02 – an existing Yara Dallol BV procedure titled “ Investigation and

Follow-up of Accidents and Near-miss Incidents”
1 INTRODUCTION

Yara International is a leading global fertilizer company with sales of fertilizer

to about 150 countries globally. As part of Yara International’s overall
upstream strategy, the company is exploring for suitable raw sources that can
be developed and used as a source to Yara International’s global fertilizer
production and directly as finished product in its product portfolio. To
complement these upstream processes, Yara International has recently started
a subsidiary company, Yara Dallol BV, which is involved in the exploration
and mining development of potash concessions in Ethiopia. These
concessions are located in the Danakil Depression, Afar National Regional
State (ANRS), Ethiopia. Yara International, through its subsidiary, proposes to
develop a potash mine – the Yara Dallol Potash Project (hereafter referred to
as the proposed Project) within these concession areas.

As part of the environmental approval process for the Project a suite of

environmental and social management plans is needed to address the issues
identified in the Environmental and Social Impact Assessment (ESIA). Several
management plans have been developed to address impacts identified in the
ESIA and are implemented as part of an environmental management system
for the proposed Yara Dallol Potash Project.

Several activities associated with the Project (during the construction,

operational and decommissioning/closure phases) require specific
management to ensure that activities are appropriately controlled to prevent
and mitigate unwanted outcomes. This Spill Prevention, Control and
Containment Plan (SPCCP) has been developed to address the general
requirements for management of unplanned spills of dangerous or hazardous
materials during the Project life cycle. These may include spillages related to:

 Hydrocarbons (including diesel, petrol, greases, oils and other lubricants);

 Drilling chemicals;
 Hazardous chemicals (viz. paints, etc.); and
 Waste water, including sewage.

The following SPCCP presents a procedural framework for reducing the

potential for spills, responding to such events and for monitoring operations
to confirm that preventative measures are in place and followed. Furthermore,
the procedures within include plans for addressing training, resources,
responsibilities, communication and all other aspects required to effectively
respond to such events.

1.1.1 Policy Statement

The development of this SPCCP has been guided by the Yara Dallol BV
Health, Environment, Safety, Quality and Product Stewardship Policy, as set
out in Box 1.1. This Policy is a high-level corporate statement of intent and

ENVIRONMENTAL RESOURCES MANAGEMENT YARA DALLOL BV

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 establishes the principles to be followed in the management of environmental
and health & safety issues.

Box 1.1 Health, Environment, Safety, Quality and Product Stewardship Policy
Statement

COMPANY COMMITMENT

Yara Dallol BV’s aim is to establish sustainable growth and the creation of shareholder and
societal value. Yara Dallol BV affirms to their stakeholders, including employees, customers and
the public, it’s commitment to continuously improve and reach standards of excellence in
Health Environment, Safety, Quality and Product Stewardship through their operations.

ENVIRONMENTAL POLICY

Yara Dallol BV will manage their business in a life cycle perspective. In its operations, Yara
Dallol BV will contribute to eco-efficiency by continuously improving energy consumption and
reducing waste, emissions and discharges. Waste that is generated will be handled and
disposed if safely and responsibly.

Yara Dallol BV will design their products and develop product applications to have the
minimum adverse effect on the environment throughout their lifecycle.

HEALTH AND SAFETY

Injuries and occupational illnesses, as well as safety and environmental incidents, are
preventable, and Yara Dallol BV’s goal for each of these is zero. Yara Dallol BV will encourage
their employees to adopt a healthy, safe life-style for themselves and their families.

Yara Dallol BV will be prepared for emergencies and cooperate with local authorities to
establish and improve their emergency preparedness.

1.1.2 Objectives

Yara Dallol BV has existing procedures that deal with response management
to incidents and/or risks associated with the environment, and more
specifically with the accidental release of hazardous material, liquid or gas to
air, water or ground. In addition to response management, Yara Dallol BV has
procedures that set out the actions required for incident reporting,
investigation and follow-up (these are described in further detail in Section 4).
These existing procedures will be documented within the overall
Environmental and Social Management System (ES-MS), and will be updated
to include detailed spill prevention, control and containment.

The objectives of this SPCCP are as follows:

1. Protect the communities and the environment through the development of

spill response and containment strategies and capabilities.

2. Structure a process to identify the sources of potential land contamination

associated with construction and operational phases of the Project.

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 3. Categorise potential spill hazards.

4. Structure a process for rapid and efficient response to and manage

hazardous material spills during the construction, operational and
decommissioning and closure phases of the Project.

5. Identify and document management measures to prevent, control and

mitigate spill events during all phases of the Project and at all operations
and facilities associated with the Project.

6. Assign responsibilities for implementing the management measures; and

7. Describe verification, monitoring and reporting measures.

1.2 PURPOSE AND SCOPE

The construction, operation and decommissioning and closure phases of the

Project will include activities that has the potential to result in spills to the
environment. The SPCCP is aimed at defining –

 A proactive hazard identification so as to prevent (or lower the likelihood)

of spill events; and

 The response process and responsibilities for managing these situations,

thus reducing likelihood and severity of inadequate management.

This SPCCP is considered to be a “live” document and will need to be

amended periodically in light of operational changes, learning experienced
during its implementation and other activities that can affect the risk profiles.

Given that the detailed design of the Project is underway and not complete at
this time, this SPCCP presents conceptual measures for spill prevention and
control and outlines the framework for developing a more comprehensive
SPCCP, which is to be completed prior to various stages of construction,
operation and decommissioning/closure. The final SPCCP will require
consultation with mine engineers and contractors and will be led by the Yara
Dallol BV management team.

1.3 LINKAGE TO OTHER ENVIRONMENTAL AND SOCIAL PLANS

This SPCCP should be read in the context of the Environmental and Social
Management System (ES-MS) (discussed in Chapter 13 of Part I of the ESIA),
which has been structured to provide a vehicle for the integrated management
of the suite of management plans described in Part III. These plans have been
designed to address a broad range of social and environmental risks.

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It is recognised that the ES-MS and associated plans are living tools that will
be constantly updated to accommodate changing circumstances.

Specifically, this plan ties in closely with the Community Health, Safety and
Security Management Plan (CHSSMP), (Annex J in Part III), the Waste
Management Plan (WMP) (Annex G in Part III), the Integrated Mine Closure
Plan (IMCP) (Annex E in Part III), the Water Management Plan (WAMP)
(Annex H in Part III) and the Emergency Response Plan (ERP) (Annex D in
Volume III). This is discussed in further detail below -

Management Plan Overlap of this Plan with Content of Other Plans

SOCIAL PLANS
Community Health, Safety and Undesired events and exposure to hazards has the potential
Security Management Plan to impact on individual’s health and safety if onsite risks are
(CHSSMP) not managed suitably.
ENVIRONMENTAL PLANS
Waste Management Plan (WMP) Management of all waste streams (including contaminated
materials) produced by Yara Dallol BV must be in place to
ensure protection to the communities and the environment.
Integrated Mine Closure Plan The IMCP has reference with respect to evaluating and
(IMCP) remedying potential contamination at the closure phase of
the proposed Project.
Water Management Plan The protection of water resources and monitoring of these
(WAMP) with respect to contamination has reference.
OCCUPATIONAL HEALTH, SAFETY AND RISK PLANS
Emergency Response Plan (ERP) The ERP has reference with respect to the development of
emergency response processes to ensure that health and
safety of workers and protection of the receiving
environment and communities is ensured.

In addition to the above, this SPCCP links with Yara Dallol BV’s existing
TOPS 0-01 and TOPS 0-02 procedures. Yara Dallol BV’s TOPS 0-01 procedure
describes the requirements for registration and reporting of incidents and near
misses associated with accidental release of hazardous material, liquid or gas
to air, water or ground. The TOPS 0-02 procedure describes the requirements
for investigation and follow-up of environmental incidents and near miss
incidents.

This SPCCP has been developed so as to compliment and makes reference to

the requirements set out in these two procedures.

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2 SUMMARY OF LEGAL AND OTHER REQUIREMENTS

A summary of the legal requirements and standards relevant to the SPCCP are
presented below.

2.1 NATIONAL LEGISLATION AND POLICY

The following Ethiopian regulation informed the development of this SPCCP:

2.1.1 Prevention of Industrial Pollution Council of Ministries Regulation

(159/2008)

This regulation is directed to industry and in particular “factories”. The

regulation does not provide a clear definition of “factories”; however, certain
sections of the regulation can be deemed applicable to the proposed Yara
Dallol Potash Project. These sections include the need for emergency response
systems and the need for monitoring of environmental safety.

2.2 INTERNATIONAL FINANCE CORPORATION (IFC) PERFORMANCE STANDARDS

The following IFC Performance Standards are applicable to this SPCCP:

2.2.1 Performance Standard 3 (Resource Efficiency and Pollution Prevention)

IFC Performance Standard (PS) 3 aims to avoid or minimise adverse impacts

on human health and the environment by avoiding or minimizing pollution
from project activities. Furthermore, the standard promotes more sustainable
use of resources, including energy and water and aims to reduce project-
related greenhouse gas emissions.

2.2.2 Performance Standard 4 (Community Health, Safety and Security)

IFC PS 4 aims to avoid adverse impacts on the health and safety of affected
community during the project life from both routine and non-routine
circumstances. Furthermore, the standard ensures that the safeguarding of
personnel and property is carried out in accordance with relevant human
rights principles and in a manner that avoids or minimises risks to the affected
communities.

The United Nations Environment Programme (UNEP) and Awareness and

Preparedness for Emergencies at Local Level (APELL) requires that all projects
will have an Emergency Preparedness and Response Plan that is
commensurate with the potential risks of the facility and that includes the
following basic elements:

 Administration (policy, purpose, distribution, definitions, etc.).

ENVIRONMENTAL RESOURCES MANAGEMENT YARA DALLOL BV

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 General Facility information including location, primary and alternate
emergency response coordinator, physical description of facilities,
surrounding and underlying geology and groundwater, description of
operations and processes, wastewater systems, facility outfalls, protection
of surface waters and personnel responsible for the development of the
contingency plan for the facility.

 Organization of emergency areas (command centers, medical stations,

etc.).

 Roles and responsibilities.

 Communication systems (such as a notification flow chart).

 Emergency response procedures to be used as guidelines to follow when a

spill, fire, explosion, or other catastrophic event causes a release of oil or
other hazardous materials to the environment.

 Emergency response procedures to be used as guidelines to follow when

there are spills in diked or containment areas, spills in un-diked areas,
spills to on-site lakes/lagoons, spills on soil, spills to receiving riverbeds,
unplanned releases of compressed gases, and releases from oil-filled
electrical equipment.

 The identification and location of emergency response equipment, and

emergency response contractors, as well as descriptions of the appropriate
containment equipment to prevent spills from reaching water bodies.

 Emergency resources.

 Facility Evacuation Plan and diagrams.

 Training and updating requirements for facility operational and

emergency response personnel.

 Checklists (role and action list and equipment checklist including an

inventory of hazardous substances, wastes, oils, and industrial gases that
have a potential for spills or accidental releases into the environment).

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3 OVERALL ACCOUNTABILITY AND RESPONSIBILITY FOR THIS PLAN

With respect to this SPCCP, Yara Dallol BV has the responsibility to ensure
that adequate measures are developed and implemented by parties, including
third parties, to prevent, control and contain spills associated with their
activities.

Moreover, Yara Dallol BV have the responsibility for defining, communicating

and monitoring the requirements of contracting third parties and suppliers
operating under their control with respect to spill management.

The roles and responsibilities within Yara Dallol BV for the implementation of
the SPCCP are presented in Table 3.1.

Table 3.1 Responsible Parties and Roles and Responsibilities

Responsible Parties Roles and Responsibilities

 Review monthly and annual spill reporting
 Review spill response drill outcomes and work with Health
and Safety Manager and Environmental and Social Manager
Dallol General Manager to identify necessary improvements
 Appoint an Emergency Response Coordinator tasked with
responding to spills in order to minimize disparate utilization
of resources
Emergency Response  Respond to spills so as to minimise disparate utilization of
Coordinator resources
 Ensure they are easily recognizable to their
colleagues/visitors and the emergency services by wearing
the orange high vis vest or coat during any evacuation
 Responsible for all occupants’ safety during evacuation and
to ensure the safety of the building before re-entering after
drill, unless his role is passed onto the Emergency Response
Coordinator
Evacuation Officer
 Keep an updated list of employees and visitors on site and
carry the name list with them during evacuation
 Ensure all occupants have evacuated the area where the
incident has taken place (including people in rest rooms,
meeting rooms, etc.)
 To be fully trained in the provision of first aid
 Ensure first-aid is given to evacuees if needed

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 Responsible Parties Roles and Responsibilities
 Distribution of the SPCCP to all parties with responsibilities
in implementing the plan (including contractors)
 Review monthly spill report
 Review quarterly report of accidents/incidents and reviews
of contractor practices
 Plan spill response drills with Dallol General Manager and
Health and Safety Contractor Managers
Manager  Develop Spill Response Training
 Lead any reviews or investigations into reported spills
 Review all contracts prior to signing and confirm these
contain requirements to meet Yara Dallol BV spill response
standards
 Receive all notifications of spills and ensure proper response
is being followed including reporting and review
 Support the Health and Safety Manager as required in spill
response planning and in development of training and
Environmental and Social
management plans to ensure environmental concerns are
Manager
addressed
 Provide regular spill reporting
 Schedule monthly inspections and audits and resolve issues
identified
Health & Safety Support  Support the Health and Safety Manager in planning Spill
Staff Response drills
 Schedule spill response training sessions for relevant staff
 Prepare monthly spill report
 Together with the Health & Safety Manager and
Environmental and Social Manager is responsible for staffing,
planning and day-to-day execution of the management
measures described under this SPCCP during the
Project Manager construction phase of this Project.
 As needed, this individual will develop and propose staff
plans and contractual language to ensure that these measures
are implemented by Yara Dallol BV staff and contractors
throughout the construction phase of the Project.
 Together with the Health & Safety Manager and
Environmental and Social Manager is responsible for staffing,
planning and day-to-day execution of the management
measures described under this SPCCP during the operational
phase of this Project.
Operations Manager
 As needed, this individual will develop and propose staff
plans and contractual language to ensure that these measures
are implemented by Yara Dallol BV staff and contractors
throughout the operational phase of the Project.
 Responsible for following the procedures and requirements
Contractor (Construction
indicated in construction and operational sections of this
and Operations)
SPCCP.
 All persons employed by Yara Dallol BV or under service
contract for Yara Dallol BV (e.g. contractor, transporter etc.),
All persons
who discover or cause an incident are responsible for
immediate reporting of the incident to his/her supervisor.

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4 SPILL MANAGEMENT DURING THE CONSTRUCTION, OPERATION
AND DECOMMISIONING/CLOSURE PHASES

4.1 SPILL HAZARD IDENTIFICATION

Yara Dallol BV will maintain a register of spill hazards associated with all
activities during all phases (construction, operation and
decommissioning/closure) of the Project.

All contractors will undertake spill hazard identification studies to identify

spill hazards associated with their operations/activities and pass these on to
Yara Dallol BV.

The spill hazard identification study will include –

 Approximate storage volumes for all hazardous materials/chemicals;

 Identification of storage and transfer locations for the various hazardous

materials/chemicals; and

 The environmental and social risks associated with each hazardous

material/chemical. These are to be obtained from each material /
chemical’s Material Safety Data Sheet (MSDS), which must be delivered
with each hazardous material / chemical assignment.

Moreover, the study will include an up-to-date plan or map of the Project site
and the locations of all managed chemical products.

Part of the process of developing the detailed spill hazard identification will
be to assess the risk of spills. Risk will be evaluated based on –

 The likelihood of a spill occurring during handling and transfer methods;

 The presence of secondary containment;

 The state of the hazardous material/chemical product (solid/liquid);

 The preventative measures designed and in-place so as to prevent/contain

spill events; and

 The potential impacts of a spill based on –

- The toxicity of the hazardous material/chemical (obtained from the

MSD sheets);
- The potential for a spill to reach surface- and groundwater sources;
- The potential volumes available for spills; and
- The potential of a spill to affect human health.

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 Chemicals with a higher risk-rating will be evaluated so as to identify
measures to reduce the risk through effective contaminant.

4.2 PRELIMINARY LIST OF HAZARDOUS CHEMICALS

A preliminary list of potentially hazardous materials/chemicals that will be

used during all phases of the Project include –

 Waste water, including sewage;

 Paints (viz. antirust, primer, auto lacquer, synthetic, enamel, metal, spray,
floor and wall paints);
 Degreasers;
 Hydraulic, transmission and engine oil (new and used);
 Assorted lubricants;
 Refrigerants;
 Petrol;
 Diesel oil;
 Aerofroth 70 frother;
 Flotigam S;
 Chemicals used for the treatment of water (viz. sulphuric acid, bisulphite,
antiscalant and chlorine);
 Drilling chemicals;
 Amine oil (product de-dusting agent); and
 Hydrogen peroxide (used for drilling).

MSD sheets associated with each of these hazardous materials / chemicals

should be made available with each consignment, and MSDS sheets for all
such hazardous materials / chemicals should be clearly displayed in each
hazardous materials / chemicals store. The measures to be taken in case of a
spill for each, should be included in the risk register (explained in Section 4.1).

4.3 SPILL PREVENTION MEASURES

The following proactive measures will be adopted so as to prevent the

likelihood of spill event:

 Training of Yara Dallol BV Staff and contractors regarding proper methods

for transporting, transferring and handling substances that have the
potential impact to human health or the environment.

 Institution of a preventative maintenance program including inspection

schedules to confirm and maintain the mechanical integrity and
operability of pressure tanks, piping systems, relief and vent values
systems, containment infrastructure, shutdown systems, controls, pumps
and associated process equipment.

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  Implementation of Standard Operation Procedures (SOPs) for handling
materials including refuelling vehicles, the use of diesel as oil blankets, the
use of diesel tanks, the use and handling of processing chemicals, and
managing secondary containment areas.

 Provision of secondary containment, drip trays or other overflow and drop

containment measures, for hazardous materials containers at connection
points or other possible overflow points. Identification and provision of all
equipment necessary to handle, transfer or transport materials properly.

 Use of transfer equipment that is compatible with and suitable for the
characteristics of the materials transferred and designed to ensure safe
transfer.

 Use of dripless hose connections for vehicle tank and fixed connections
with storage tanks.

 Installation of gauges on tanks to measure volume inside.

 Review of all potential pollutants characteristics prior to introduction to

site and establishment of proper storage, handling and transportation
procedures and spill risk analysis.

 Material Safety Data Sheets (MSDS) for all contaminants on-site will be
readily available. These will include human health effects of chemicals
handled and will be included in the required chemical environmental and
safety training for all employees handling or otherwise exposed to the
contaminants. All appropriate personal protective equipment, handling
and response procedures will also be identified in the MSDS or otherwise
recommended by the suppliers/manufacturers and will be incorporated
into a Spill Prevention Control and Containment Plan and followed by the
Project staff.

 The Project will retain a qualified third-party to review and audit chemical
storage and distribution systems, including appropriate testing every five
years.

 Bulk transfers of chemicals during delivery will be observed by Yara

Dallol BV personnel trained in preliminary hazard analysis methods.

 SOPs for chemical transportation, unloading, transfer, storage, handling,

use and disposal shall be developed, kept current, effectively implemented
by trained personnel.

4.4 SPILL CONTROL AND COUNTERMEASURES

The following spill control and countermeasures will be followed in the event
of a spill incident:

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  Maintenance of updated emergency contact information list at all spill
response kits locations.

 Maintenance of spill route maps (perceived overland flow path [flow

gradient] and likely contamination point [i.e. surface water features,
potable boreholes etc.] of a given contaminant substance) at potential spill
locations.

 Document availability of all spill response equipment that is capable of

handling a large spill.

 Document availability of specific personal protective equipment and the

necessary training needed to respond to different potential spills.

 Maintenance of spill response kits on all Project fuel and lubrication sites
and vehicles.

 Maintenance of spill response guidelines at all spill response kit locations.

 Maintenance of an up-to-date plan of the Project site showing the location

of all contaminants, spill response kits and other response equipment.

 Maintenance of an updated table of all contaminants on-site and

recommended spill response procedures.

 Development, implementation and regular training and testing of a

facility-wide Spill Response Plan.

 First-aid training for all relevant mine personnel.

 All spills will be reported to appropriate management personnel.

4.5 SPILL RESPONSE SUB-PLANS

Site-specific spill response sub-plans will be developed by Yara Dallol BV.

These sub-plans will be developed and implemented for areas where large
volumes of hazardous chemicals are stored (for example – the tank farm in the
footprint of the processing plant, workshop and vehicle repair area and
blanket oil storage areas at the well fields in North Musley). These sub-plans
will address:

 Roles in the event of a spill including: spill coordinator (the person on the
ground at the spill site, who is responsible for immediate actions taken to
contain the spill, respond to immediate dangers, notify necessary
responders) and the rest of the mine site and personnel.

 Spill response equipment to be kept on site to contain spills.

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  Internal and external notification procedures.

 A communication system that will be followed during the spill, first

response and clean-up and communication infrastructure required i.e.
radios, telephone systems etc.

 Facility evacuation routes and procedures.

 Post-event activities such as clean-up and disposal, incident investigation,

employee re-entry and restoration of spill-response equipment.

 Reporting requirements at the time of the spill and after the spill.

4.6 TRANSPORTATION OF HAZARDOUS MATERIALS AND CHEMICALS

The transportation of certain substances (viz. diesel) presents the potential for
spills due to traffic accidents or other accidents or incidents en-route to or
from the Project site. Precautions that will be followed include:

 Contractors will use transportation vehicles and tanks suitable for the
materials and transportation routes used. These vehicles and tanks will be
maintained in adequate condition to insure proper handling and safety of
chemicals.

 Contracts involving chemical transportation will require compliance with

applicable laws as well as Yara Dallol BV policies and procedures and will
require responsible management of chemicals including emergency
response and spill clean-up.

 Truck drivers will be required to notify the site of their departure time and
arrival time and maintain a log of travel.

 All vehicles will be equipped with spill response kits appropriate to the
materials being transported. The contractor will be required to maintain
these in good condition and working order.

 Drivers will be trained in spill and emergency response and will have a
means of communicating with the site, their administrative offices and
emergency personnel for the entire transportation route.

 Up-to-date emergency contact information and monitoring sheets and

manifests documenting the volume, phase and characteristics of the
chemical being transported will be carried with each shipment.

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4.7 SPILL EMERGENCY PROCEDURES

In the event of a hazardous spill onsite, the following emergency procedures

must be implemented:

 The Emergency Response Coordinator must be notified.

 Personnel in the immediate vicinity of the hazardous spill, including the

designated Evacuation personnel must be immediately notified.

 The risk of explosion (if known) must be communicated to the Dallol

General Manager and Health and Safety Manager onsite.

 Vehicle ignition or any power supply where the hazardous spill occurred
must be immediately switched off.

 If possible, all drains and valves in the vicinity of the hazardous spill must
be closed.

 The application and use of hazardous spill kits must be used ONLY by
those trained to do so.

 The appropriate hazardous spill response and clean-up contractor must be

notified and all contaminated material as a result of the spill must be
suitably disposed of off-site.

In addition to the above, the Yara Dallol BV procedure relating to the

reporting of incidents (TOPS 0-01) provides a classification of environmental
incidents into 5 categories of severity, namely –

 Major Severity 1 –

- Accidental release of hazardous material, liquid or gas to air, water

or ground with serious long terms environmental impacts.
- International Media Coverage.
- Clean-up cost or legal penalty of more than 10 million Euros (or 15
million USD).

 Major Severity 2 –

- Release with serious short term environmental impacts.

- National media coverage.
- Clean-up cost or legal penalty in the range of 1 to 10 million Euros
(or 15 million USD).

 Major Severity 3 –

- Release with the potential for short term local impact.

- Local media coverage.

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 - Permit breach with the potential for legal charges.

 Major Severity 4 –

- Release with no apparent environmental impact.

- Permit breach without legal charges.

 Major Severity 5 –

- Minor release without environmental impacts or negative

publicity.

As per Yara Dallol BV’s existing procedure (TOPS 0-01), the following
incidents (as set out above) must be reported without delay by the Dallol
General Manager to the Yara International Head Office –

 All environmental incidents in severity class 1, 2 and 3; and

 All environmental incidents with a potential for severity class 1 and 2.

All spill incidents will be registered by using Yara’s Synergi database. Details
of this process are provided in the TOPS 0-01 procedure. Moreover, all spill
incidents will be investigated for identification of causes and preventative
actions. All investigations must be organised and carried out in accordance
with Yara Dallol BV’s procedure on investigation and follow-up of
environmental spill incidents and near miss incidents (as detailed in TOPS 0-
02).

The actions resulting from any formal or informal investigations will be used
to update this SPCCP.

4.8 TRAINING

Chemical environmental and safety, spill response and first aid training will
be delivered to all relevant employees. Training will be provided within one
month of an employee’s start-date. Chemical environmental and safety and
first aid training will be provided by certified instructors. Spill response
training will be provided by a competent persons and environmental, health
and safety staff as necessary. Key personnel will be identified to receive
preliminary hazard analysis training. The training will be conducted on a
regular basis. The frequency and timing of training is at the discretion of the
Dallol General Manager, Health and Safety Manager and Environmental and
Social Manager, but is recommended to take place at least once a month.

The Health and Safety Manager shall distribute the SPCCP (together with the
ERP and associated Emergency Evacuation Plan) to all parties in charge of
ensuring the plans implementation. All relevant information in the SPCCP
(and the ERP and associated Emergency Evacuation Plan) will be
communicated to employees and contractors. This information will include

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information on potential spill risks/threats for areas where large volumes of
hazardous chemicals are stored, appropriate first person response to spill
incidents and notification procedures.

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5 COSTS FOR SPILL PREVENTION, CONTROL AND CONTAIMENT

5.1 CONSTRUCTION AND OPERATIONAL PHASE

Costs for implementation of preventative and containment measures will be

borne by Yara Dallol BV for work carried out by Yara Dallol BV; however,
costs for implementation of preventative and containment measures will be
borne by contracting third parties where responsibility for hazards is allocated
to such parties.

The cost for auditing and verification of contracting third party performance
will be included in operational budgets by Yara Dallol BV.

5.2 DECOMMISSIONING AND CLOSURE PHASE

The costs associated with decommissioning and closure, as well as any post-
closure, is covered by the amount accrued annually for the life of the Yara
Dallol Potash Project.

Effective implementation of the plan and underlying operational procedures

will ensure only insignificant contamination is present at closure.

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6 VERIFICATION, MONITORING AND REPORTING

6.1 VERIFICATION, MONITORING AND REPORTING PLAN

All high risk spill hazards will be monitored on a frequency to be determined

in the appropriate management procedures for the identified hazards. Yara
Dallol BV will include such monitoring into their auditing programs as
developed as part of the Yara Dallol Potash Project ES-MS.

Yara Dallol BV will monitor (on an on-going basis) contractor performance

against this SPCCP.

Monitoring will include:

 Bi-weekly inspections;

 Quarterly reporting by contractors regarding preventative maintenance

programs;

 Spill reporting at the time of the incident and monthly spill reporting
developed by Health and Safety department;

 Bi-annual spill response drills; and

 Annual reporting on training.

During bi-weekly inspections any missing response equipment, personal

protection equipment, or documentation will be replaced or improved as
necessary.

Quarterly reporting will identify any upcoming required preventative

maintenance required as well as what preventative maintenance performed
over the quarter. The Health and Safety Manager will track any outstanding
maintenance and require the contractor to complete it in a timely fashion.

The spill response drills and spill reporting will provide information
regarding required revisions to training, the spill response plan or other
aspects of the SPCCP. Each spill reported will be reviewed by Health and
Safety Manager and actions identified where possible to improve the site’s
overall planning. Updates/revisions will be made on a bi-annual basis or
sooner if the deficiency identified is considered urgent. On a bi-annual (twice
annually) basis the Key Performance Indicators will compared against past-
performance and analyzed for trends to determine if there are areas the can be
improved.

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6.2 KEY PERFORMANCE INDICATORS

The following Key Performance Indicators (KPIs) are suggestions and can be
measured and used to evaluate the Project’s performance with respect to its
stated objectives and commitments:

 Monthly and annual volumes of materials transported and handled by the

Project that could result in harm to human health or the environment in
the event of an accident or spill;

 Monthly and annual number and volume of accidental small releases to

the natural environment (including soils and water);

 Annual and monthly number of major spills occurring at the site of the
Project;

 Number of hydrocarbon releases;

 Number of chemical releases;

 Number of other releases;

 Number of employees trained in spill response (compared to number of

employees working with or around contaminants);

 Number of employees trained in first aid (compared to number of site

personnel);

 Number of employees trained in the safe and environmentally sustainable

handling of chemicals on-site (compared to number of employees working
with or around contaminants); and

 Response time and methods used in drills.

6.3 COSTS FOR VERIFICATION AND MONITORING

Costs for verification and monitoring of performance by Yara Dallol BV will

be included in the operating cost of the Yara Dallol Potash Project.

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7 SPILL PREVENTION, CONTROL AND CONTAINMENT PLAN SUMMARY

Table 7.1 Complete Project Lifecycle

Impact Objective Mitigation/Management Measures Monitoring Plan Responsibility

Potential negative Development and Review the SPCCP to confirm specific Annual review  Dallol General Manager
impacts to environment, implementation of a suitable procedures are in place to address prevent,
workforce and SPCCP control and mitigate spill events during all  Health and Safety
community from spills phases of the Project and at all operations Manager
and facilities associated with the Project
 Environmental and Social
Manager
Update the SPCCP Review of the SPCCP in the event of a Review of the SPCCP in  Health and Safety
change in process within the mining or the event of a change in Manager
support operations process within the
mining or support
operations
Manage the SPCCP Maintenance of spill event contact Annual review of  Health and Safety
processes information, location of contaminates, processes Manager
appropriate response procedures and
location of response equipment  Environmental and Social
Manager
Manage the SPCCP Maintenance of spill response equipment Annual inspection of  Health and Safety
processes equipment Manager

 Health and Safety

Support Staff
Provide SPCCP relevant Provide spill response training to all Document training  Health and Safety
training employees and contractors, including first Manager
aid training Annual review of
candidates  Health and Safety
Support Staff

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Impact Objective Mitigation/Management Measures Monitoring Plan Responsibility
Provide SPCCP relevant Provide all personnel involved in mineral Document training  Health and Safety
training processing and process chemical Manager
management appropriate training on how Annual review of
to recognise and respond to situations candidates  Environmental and Social
which can result in releases to the Manager
environment
 Health and Safety
Support Staff
Inspect chemical and fuel Carryout inspections and assess integrity Annual inspection of  Health and Safety
storage facilities of all formal facilities used to store storage facilities Manager
chemicals and fuels
 Health and Safety
Support Staff
Oversee chemical transfer Inspection of all chemical transfers taking As and when chemicals  Health and Safety
activities place on site and/or fuel are Support Staff
delivered/removed
from site
Report of spills Carryout the appropriate internal and Review of all spill  Health and Safety
external reporting reports Manager

 Environmental and Social

Manager

 Health and Safety

Support Staff

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